TTBS / OSH Act Audit Preparation for Inspection Companies
A TTBS / OSH Act audit runs in 6 stages, beginning with establish the statutory route first: identify which items on the client's site.. Trinidad and Tobago Bureau of Standards (TTBS), including its laboratory accreditation arm TTLABS; the Occupational Safety and Health Authority and Agency; the Minister responsible, who licenses boiler examiners; the Ministry of Energy and Energy Industries for petroleum operations tests the system by sampling finished.
Trinidad and Tobago has no NDT-specific regime, and the gap itself is the commercially important fact. TTBS's accreditation arm, TTLABS, accredits laboratories to ISO/IEC 17025 and ISO 15189 only, so there is no domestic route to ISO/IEC 17020 inspection body accreditation; firms go to JANAAC in Jamaica or to a foreign accreditation body, which is how TTBS's own Implementation Division came to hold ISO/IEC 17020:2012 accreditation. What is legally binding sits elsewhere. Under the Occupational Safety and Health Act, Chap. 88:08, and the Boilers Regulations and Air Pressure Containers Regulations continued in force by section 98(2), steam boilers and air pressure containers must be thoroughly examined every twelve months by a person holding a Ministerial licence who is independent of the occupier, owner or hirer. What separates firms that clear an audit from firms that collect findings is not the quality of the documentation but whether it describes what actually happens.
Source: Occupational Safety and Health Act, 2004 (Act No. 1 of 2004), Chap. 88:08, as amended by Act No. 3 of 2006, Laws of Trinidad and Tobago revised edition, read directly: the Occupational Safety and Health (Prescribed Forms) Order (GN 187-1948) items 18 Hoists or Lifts, 19 Steam Boilers and 20 Air Pressure Containers; the Boilers Regulations (GN 2-1949) including the annual and other examinations provisions, the boiler examiner licence and independence requirement, Gazette publication of licences and the list of boiler examiners on 1 January each year, and the twenty-one day report filing period; the Special Provisions for Safety in the Case of Air Pressure Containers Regulations (GN 3-1949) including the competent person requirement; all continued in force by section 98(2). The Act, except section 98, came into operation by Proclamation LN 48/2006 on 17 February 2006, with section 98 brought into force by 17 August 2007, repealing the Factories Ordinance (Ch. 30 No. 2), the Employment of Women (Night Work) Act and the Gas Cylinders (Use, Conveyance and Storage) Act. TTBS website and TTLABS accreditation page (accessed August 2026) confirming accreditation to ISO/IEC 17025 and ISO 15189, ILAC and IAAC membership, and that the TTBS Implementation Division operates as an ISO/IEC 17020:2012 inspection body accredited by JANAAC; JANAAC website confirming ISO/IEC 17020 among its scopes alongside ISO/IEC 17025, ISO/IEC 17021-1 and ISO 15189, and its IAAC MLA and ILAC MRA signatory status; CROSQ report of TTBS Certification Division accreditation by JANAAC to ISO/IEC 17021-1:2015 on 3 October 2022. The Standards Act number and chapter establishing TTBS could not be verified from a primary source in this session and is therefore not stated.
| Stage | What happens | What it tests |
|---|---|---|
| Stage 1 | Establish the statutory route first: identify which items on the client's site are steam boilers, economisers, superheaters or air pressure. | Where the paperwork is tested against itself |
| Stage 2 | Confirm the examiner's licence is current and that he is not in the employ of the occupier of the premises,. | Where the paperwork is tested against practice |
| Stage 3 | Carry out the examination in the prescribed order: the boiler cold, with interior and exterior prepared to the examiner's satisfaction,. | Where the paperwork is tested against practice |
| Stage 4 | Report on Forms 7 and 8, signed by the person making the examination, and enter or attach them to the. | Where the paperwork is tested against practice |
| Stage 5 | Where the client requires third-party accreditation, apply to JANAAC or another recognised accreditation body for ISO/IEC 17020 accreditation, since TTLABS. | Where the paperwork is tested against practice |
| Stage 6 | Maintain the twelve-month cycle, dated from completion of the examination under normal steam pressure | Where the paperwork is tested against practice |
| Renewal | The statutory intervals are fixed and verifiable. Steam boilers and all fittings and attachments: thorough examination at least once in every period of twelve months and also after any extensive repairs, with the twelve months running from completion of the examination under normal steam pressure; the competent person may extend that period by not more than one month in an emergency where shutdown would cause serious loss or damage, after which the next examination must fall within the succeeding eleven months. Air pressure containers: thoroughly cleaned, examined and hydraulically tested every twelve months. Hoists and lifts: thoroughly examined every twelve months. Boiler examiners' licences and the examination fee schedule are published in the Gazette on 1 January each year. | Diarised from the certificate date, not the last audit |
How long does TTBS / OSH Act audit preparation take?
Document work — the written practice, procedures and quality manual — takes weeks. What cannot be compressed is documented experience and records history: on-the-job hours accrue in real time, and calibration and certification history cannot be back-filled. Firms that start when the audit is scheduled rather than announced clear it without findings.
What does Trinidad and Tobago Bureau of Standards (TTBS), including its laboratory accreditation arm TTLABS; the Occupational Safety and Health Authority and Agency; the Minister responsible, who licenses boiler examiners; the Ministry of Energy and Energy Industries for petroleum operations look at first?
Records, not manuals. A manual states intent; records show practice. The usual opening move is to take a completed job and trace it back to the technician's certification, the instrument's calibration, the approved procedure and the report — and see whether all four reconcile.
What are the most common TTBS / OSH Act findings?
Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence, The examiner is on the occupier's payroll, or the owner's or hirer's, breaching the independence requirement the Boilers Regulations impose, Only the cold examination performed and the examination under normal steam pressure omitted, so the twelve-month clock never legitimately restarts, Forms 7 and 8 completed but not entered in or attached to the General Register within twenty-one days of the examination. Almost all of them are evidence problems rather than capability problems: the work was done correctly and the proof was not kept, or was kept somewhere the firm could not retrieve during the audit.
Can a consultant attend the TTBS / OSH Act audit?
Yes, and it changes the outcome. Someone who has sat through the same audit at other firms answers in the auditor's own terms, produces the right record without a search, and stops a clarification turning into a finding. The firm still owns every answer — the consultant does not speak for it.
What happens after a TTBS / OSH Act finding?
A corrective action with a deadline, and evidence of closure at the next audit. Repeat findings are treated far more seriously than first ones, because they show the corrective-action system itself is not working.
Does TTBS / OSH Act require a pre-audit or gap assessment?
Not as a requirement, but the arithmetic favours it: a gap assessment finds the same evidence problems the auditor would, without the finding attached, and while there is still time to fix them. Firms entering their first TTBS / OSH Act audit blind typically collect findings that a sampling exercise would have caught.
What the auditor asks to see
- Written practice to ASNT SNT-TC-1A, signed and dated by the Level III, covering every method, level and technique the company offers
- Personnel certification files with training records, documented experience, examination papers and grading, and current near-vision and colour differentiation records
- Written NDT procedures approved by the Level III against the code the client cites: ASME BPVC Section V, API 510, API 570, API 653 or AWS D1.1
- Boiler examiner's licence issued by the Minister, unsuspended and uncancelled, for anyone examining steam boilers, economisers, superheaters or air pressure containers
- Prescribed Form No. 7, report of examination of the boiler when cold, signed by the person making the examination
- Prescribed Form No. 8, report of examination of the boiler under normal steam pressure, signed by the person making the examination
- General Register entries or attachments, filed within twenty-one days of each statutory examination
- Hydraulic test certificate specifying the maximum permissible working pressure and the tests applied, for any new or previously used boiler before it is taken into use
- Equipment calibration certificates and reference block traceability records
- Radiation-protection authorisation for gamma radiography sources, operators and source transport
Findings to close before the audit
- Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence
- The examiner is on the occupier's payroll, or the owner's or hirer's, breaching the independence requirement the Boilers Regulations impose
- Only the cold examination performed and the examination under normal steam pressure omitted, so the twelve-month clock never legitimately restarts
- Forms 7 and 8 completed but not entered in or attached to the General Register within twenty-one days of the examination
- A second-hand or relocated boiler taken back into use with no prior examination, hydraulic test and report
- Air pressure containers treated as out of scope and inspected ad hoc, rather than on the twelve-month clean, examine and hydraulically test cycle
- "Accredited" claimed on tender documents when the firm holds only ISO 9001 certification; TTLABS accredits laboratories, not inspection bodies, and the distinction is routinely blurred in local bids
- Written practice imported unchanged from a US parent, listing methods and techniques the local branch has no certified Level III to support
Related: the TTBS / OSH Act overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.